The corporate income tax raises a larger share of revenue in developing countries than in rich ones, often from a handful of large firms — which makes it both vital and vulnerable. It is also the tax most exposed to a globalised economy in which profits can be shifted across borders at the stroke of an accountant's pen. This module covers the design of the corporate tax and the international fight over where profits should be taxed.
Why tax corporations at all?
A corporation is a legal fiction; ultimately people bear all taxes. So why tax companies rather than just the shareholders? Three reasons: it is a backstop to the personal income tax (without it, individuals would shelter income inside companies untaxed); it is an efficient withholding point (taxing a few large firms is far easier than taxing many dispersed shareholders, especially foreign ones); and it captures location-specific rents (returns to natural resources, infrastructure, or market access that a country can tax without driving the activity away). The incidence, though, does not stay on 'capital' — in an open economy where capital is mobile, a meaningful share of the corporate tax is shifted onto labour (lower wages) and consumers, a point the Public Finance course develops. Taxing companies is not the same as taxing the rich.
The profit-shifting problem
How multinationals move profit
A multinational pays tax where its profit is booked, and it has wide latitude over where that is. The main channels: • Transfer pricing — setting the prices at which subsidiaries trade with each other to book profit in low-tax jurisdictions (over-charge the high-tax subsidiary for inputs/services from a tax-haven affiliate). • Debt shifting — loading the high-tax subsidiary with intra-group debt so interest deductions move profit to the lender in a low-tax country. • Intangibles — locating patents, brands, and IP in a tax haven and charging royalties from operating subsidiaries. The result: profit is recorded where it is taxed least, not where the real activity happens. The scale is enormous — hundreds of billions of dollars of profit shifted annually — and developing countries, reliant on corporate tax from extractive and multinational firms, lose disproportionately.
BEPS and the two-pillar reform
The OECD/G20 response is the Base Erosion and Profit Shifting (BEPS) project, and now a two-pillar deal agreed by over 130 countries:
- Pillar One — partially reallocates taxing rights over the largest, most profitable multinationals to the market jurisdictions where their customers are, even without a physical presence. It targets the digital-economy problem (a firm earning billions in a country it has no office in) but is narrow and contested.
- Pillar Two — a global minimum corporate tax of 15%: if a multinational's profits in any jurisdiction are taxed below 15%, other countries can 'top up' the tax to 15%. The aim is to put a floor under tax competition and remove the point of shifting profit to zero-tax havens.
- The catch for Africa — the deal was designed largely by and for rich economies; the African Tax Administration Forum (ATAF) and others argue it gives too little to source/developing countries and that the 15% floor is low. Many African countries already levy more than 15%, so Pillar Two may benefit haven-adjacent rich countries more than them.
Tax incentives and the race to the bottom
The evidence on incentives is damning
Governments offer tax holidays, reduced rates, and special-economic-zone exemptions to attract investment, and compete with neighbours to do so — a race to the bottom that erodes everyone's base. The evidence (IMF, World Bank, and investor surveys) is consistent and uncomfortable: tax incentives are usually NOT the decisive factor in investment decisions (firms care more about market access, infrastructure, skills, and stability), so most incentives are redundant — they reward investment that would have happened anyway, forgoing revenue for nothing. They also create avoidance opportunities (round-tripping, relabelling existing activity as new), are captured by the connected, and are hard to reverse. The professional consensus is to minimise discretionary incentives, and if any are used, to prefer cost-based ones (investment allowances tied to actual capital spending) over profit-based ones (tax holidays, which most reward the most profitable, least marginal investments).
Exercise
A multinational mining company operates a large, profitable mine in a country but reports almost no taxable profit there. Investigation reveals it buys 'management services' and 'marketing' from a related company in a zero-tax jurisdiction at high prices, and the local subsidiary is heavily loaded with intra-group debt. Separately, the company received a 10-year tax holiday to build the mine. (1) Identify the profit-shifting channels at work. (2) Explain how Pillar Two might (and might not) help this country. (3) Evaluate the tax holiday using the incentive evidence. (4) Recommend concrete domestic countermeasures the country could adopt without waiting for the global deal.